Action Alerts

***PRESS RELEASE July, 17, 2009***

contact: Gary Macfarlane, Friends of the Clearwater (208) 882-9755

Moscow, Idaho-- Friends of the Clearwater issued a statement today on the recent draft Travel Plan released by the Clearwater National Forest. "Despite the listed alternatives, the plan fails to protect critical wildlife habitat and maintain important water quality levels throughout the National Forest."

"Instead of starting with a baseline of all roads and trails being open to motorized recreation and then choosing which ones to close, just the opposite should occur. A responsible travel plan should emphasize resource protection and outline objectives which reflect land stewardship," said Brett Haverstick, Friends of the Clearwater intern.

In 1987, the Clearwater National Forest issued a forest plan to protect the natural resources and Wilderness values of our public lands. Since then, motorized recreation users have been allowed to freely travel on both roads and trails, severely degrading both terrestrial and aquatic habitat. Motorized recreation users have also been permitted to travel through many roadless areas. Friends of the Clearwater feels that the allowance of such actions is in direct violation of managing for Wilderness integrity.The current plan to allow motorized recreation into the Weitas Creek roadless area is unacceptable.

Trail systems throughout the Clearwater National Forest were never designed for motorized recreation vehicle use. The continued allowance of these activities will only further degrade the resource and lead to increased erosion and soil compaction.

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Friends of the Clearwater Clearwater Travel Plan Scoping Letter (from January 2008)

January 10, 2008

Tom Reilly
Clearwater National Forest Supervisor
12730 Highway 12
Orofino, ID 83554

Lochsa Ranger District, Kamiah Ranger Station
Attn: Lois Foster, Interdisciplinary Team Leader
Rt. 2 Box 191
Kamiah, ID 83536
comments-northern-clearwater@fs.fed.us

RE: Clearwater National Forest Travel Plan Scoping Letter

Sent Via Email and US Post:

Dear Supervisor Reilly and Team Leader Foster:

This comment is from Friends of the Clearwater, the Lands Council, the WildWest Institute, Alliance for the Wild Rockies, Wildlands CPR. Center for Biological Diversity, Friends of the Lolo Trail, and Montana backcountry Alliance. We address the issues starting with a brief history of our involvement. We then lay out crucial issues and problems, some of which the agency must address now, including a detailed analyses of specific areas and conclude with a summary and recommendation.

Comprehensive Travel Planning on the Clearwater National Forest (CNF), mandated by the 1987 Forest Plan, has yet to occur. While the current process is a step in the right direction--most importantly, it seems to be comprehensive as it includes winter use as well--it is also separate from forest planning, which may make comprehensive recreation planning and management more difficult.

The main body of the comment letter is divided into four sections:

1) comments on the process and legal mandates.
2) ecological, biological, and social information showing that large areas outside of designated wilderness should be closed to all vehicle use and a discussion of NEPA and alternatives based upon ecological, biological and social information.
3) specific comments on areas (including trails within them) that should be closed to all vehicle use.
4) summary and recommendations for an alternative

Before that, we wish to address our involvement. The organizations have been involved in motor vehicle issues on the forest for a long time. We refer you to our past correspondence, and incorporate that detailed body of information into this comment letter. Specifically, we have addressed the failings of Forest Service in past correspondence (submitted from Friends of the Clearwater and/or all organizations), provided detailed monitoring reports showing damage from off-road vehicles or ORVs including ATVs, motorcycles, and snowmobiles, and asked that the agency follow the law.

Wildlands CPR works to revive and protect wild places by promoting watershed restoration through road removal, preventing new road construction, and stopping off-road vehicle abuse. We work cooperatively with diverse communities to protect and restore our remaining wild places while fostering a growing citizenry that supports our goals. Wildlands CPR has been working on the Clearwater National Forest for many years, specifically focusing on monitoring of removed roads. We routinely submit comments on numerous forest management decisions in this region and across the nation.

The Process and Legal Mandates

Listed below are subheadings, which go into greater detail, about the process and legal mandates, some of which have been intentionally ignored. Unfortunately, many of these mandates would still not be implemented by the proposed action.

Process Problems

The CNF designed a form for proposing motorized routes some time ago and encouraged those interested in designating more motorized routes to do so. No such form for proposing trails or roads for foot or horse traffic exists. We feel that by focusing on promoting vehicle use during this process a significant portion of users have been left out. This skewed comment gathering process might create a situation where greater weight is given to comments made by vehicle users compared to others. Indeed, the agency's website reflects this bias, as did the ORV event masquerading as public lands day a few months ago.

In other words, the CNF has specifically reached out to and courted the motorized community for comments on which trails should be open or closed to motorized use. An equal effort at reaching out to other members of the public has not occurred. The CNF should make a concerted effort to gather information from all interested parties before making any decision on what routes should be added to the travel system.

We also ask that the CNF not reward rogue ORV use by considering addition of illegally created routes to the system. These routes are unauthorized and were not properly analyzed under NEPA before their creation. These routes were not located or constructed using Best Management Practices, which leads to concerns that the environmental effects of these routes cannot be fully minimized. Other forests have made the decision not to consider addition of user created routes to the transportation system. For example, the Idaho Panhandle National Forests ranger districts have thus far refused to allow illegal routes in their process.

Comprehensive Recreation Management

We commend the CNF for choosing to evaluate wintertime snowmobile use. It is a positive step. However, it is not clear that this will actually be a comprehensive look at vehicle use off main system roads. Many trails and roads are missing from the draft maps. Will the CNF be taking a full and comprehensive look at roads and trails under the new ORV regulations and the fairly recent roads policy?

Also, this undertaking amounts to de facto comprehensive recreation management as it will decide the fate of backcountry areas into the future. Permanently opening areas to ORV use is close to being an irretrievable commitment of resources. This needs to be considered in a broader perspective. For example, how will this process bias the upcoming forest plan revision?

Forest Service Failure to Follow the Law

Vehicle management on the Clearwater National Forest has failed to comply with the forest plan, the executive orders on ORVs, and NEPA. These problems have been detailed in our past comments. We have compiled them here.

Forest Service Failure to Follow Executive Orders 11644 and 11989

Presidents Nixon and Carter recognized the threats to public lands from unmanaged off-road vehicle use in the 1970s more than thirty years ago. They issued two Executive Orders (#11644 and #11989) that guide off-road vehicle use to this day. They clearly state:

(1) Areas and trails shall be located to minimize damage to soil, watershed, vegetation, or other re-sources of the public lands.
(2) Areas and trails shall be located to minimize harassment of wildlife or significant disruption of wildlife habitats.
(3) Areas and trails shall be located to minimize conflicts between off-road vehicle use and other existing or proposed recreational uses…

The Forest Service has failed in its duty to American citizens by ignoring the mandates in the executive orders.

Forest Service Failure to Follow the Forest Plan

Semi-Primitive Non-Motorized Recreation Opportunity Spectrum

The CNF has mandatory direction to, "Use the Recreation Opportunity Spectrum (ROS) and Recreation Opportunity Guide (ROG) as guides to provide a full array (emphasis added) of recreation." (forest plan, page II-21, standard 2a). The agency must also regulate use of roads, trails, and specified areas according to Executive Order 11644, planning direction in the forest plan (appendix F),and in conformance with the ROS designations for specific areas. (forest plan, page II-22, standard 2i). The forest plan standard makes the ROS an allocation, not merely an evaluation process. Yet, no areas have been established on the Forest for semi-primitive, non-motorized recreation year-round, including recommended wilderness, with the exception of the tiny Elk Creek Falls area on the Palouse District.

The proposed action makes a weak attempt to correct this violation by finally recommending some A-3 areas and some B-2 management areas as closed to vehicles year-round (NOTE: Currently, these areas are not closed to snowmobiles and some B-2 areas have wheeled vehicle use)

Allowance of ATVs on Closed Trails
The forest plan in appendix F makes it clear that all trails are normally closed to vehicles with more than two wheels. Only trails specifically permitted as open to ATVs are trails where use by motorized vehicles with more than two wheels are permitted. However, trails that were only open to two wheeled vehicles in travel plans that predated the forest plan (Fish Lake, for example) have been not merely opened but allocated to ATV use over the years. All except one of these changes occurred WITHOUT ANY NEPA COMPLIANCE OR PUBLIC INVOLVEMENT! There is only one exception, trail 229, which went through public involvement, but that trail decision violated the forest plan anyway and you have been made aware of this situation.

In 1993, the Forest Service reached a settlement agreement with several organizations that challenged the forest plan in court. That agreement added areas proposed for wilderness by Idaho's Rep. LaRocco to the recommended wilderness category (area B-2) in the forest plan (see below). While recommended wilderness areas were not explicitly closed to motorized vehicles year-round (the plan itself was silent), the language in the plan, plan EIS and ROD implies that motorized use would not be allowed.

Elk Habitat Protection
The forest plan ROD mandated elk habitat standards that require closure of all B-2, C-1, A-3, and C-6 areas to all summer motorized use, according to agency elk habitat protocol. This mandate has never been followed.

The Clearwater National Forest came out with OHV (sic) guidelines for ORV and motorized use on the forest in 1995. Those guidelines were somewhat inconsistent with the forest plan, specifically the ROD requirements for summer elk habitat. Furthermore, there are trails in specific management areas that do not even meet those guidelines. Those guidelines close certain trails to ORV use after trail reconstruction because the reconstruction would make motorized use much more likely in areas that had never seen the use (or much use) before. That increase of use would have violated the standards for those management areas. This has not been done. Some of these problems are discussed in the area descriptions later in this comment.

Increasing Motorization

Since the Forest Service has allowed motorized use to encroach on areas where it has never been (or was not common) before, and continues to allow that encroachment, there are few areas where one can escape motors. Indeed, the motorization of the Fish Lake trail and the entire Weitas Creek IRA are examples. The Weitas Creek IRA, which is the most important wildlife habitat on the Clearwater National Forest, was traditionally a nonmotorized area. The incremental motorizing of the backcountry is illegal (see for example The Mountaineers v. US Forest Service, 2006; North Cascades Conservation Council v. US Forest Service, 1999; and Washington Trails Assoc. v. US Forest Service, 1996). It also conflicts with the forest plan ROD.

As such, the current situation is not what should legally be the current situation, but a shifting target that constantly is opening more trails in sensitive areas to ORV use without NEPA and in spite of the fact most citizens who visit the Clearwater National Forest do not do so to ride ORVs. The so-called current situation, as represented in the scoping list and scoping map (and even the past guides), ignores the executive orders on ORVs and the direction in the forest plan. Policy and regulations are clear; the default position, absent NEPA and the analysis of minimizing damage and conflict as required by the executive orders, is that trails and areas are to be closed until compliance with the law can be assured. On the Clearwater National Forest (with the exception of part of the Palouse District) the law has not been followed. The agency is continuing to open up trails to ORVs that have been previously not been used and/or were closed in the past. A comparison of past travel guides shows some of these problems.

The baseline travel management system that will be used in the DEIS to evaluate the effects of the proposed action should only include routes which have been evaluated during a NEPA process. This will insure an accurate evaluation of the impacts of the proposed action. Please provide a listing of the NEPA decisions that authorized each route on the travel management system in the DEIS.

Inconsistencies/Questions

Agency documents, both present and past, are inconsistent. This had led to an informal policy of if, at any time, an area has not been clearly and formally closed to any type of ORV use, it shall be open to all ORV use. Again, the default position is open unless expressly closed. Such a policy is directly in conflict with the executive orders which mandate trails be open only where conflicts and resource damage do not occur, after appropriate analysis.

There is also inconsistency in the forest plan, ORV guidelines, executive orders and what the agency is proposing. Why is there this inconsistency?

The current information provided for this scoping process does raise some puzzling concerns. First, what is the current situation? It has been a moving target. The various annual guides have allowed motorization of specific trails/roads and snowmobile use nearly everywhere. This was all done without NEPA. In other words, what will be the no action alternative for this process? Will it reflect the illegal and gradual motorization that has occurred since the executive orders and forest plan or will it reflect an assumed compliance with those legal mandates (see the above section)?

This is an important question in part, because the scoping information contains changes to the latest guide for the no action alternative. Please explain how the no action alternative can be a shifting target absent any prevision travel decision dating back to the forest plan in 1987?

Please ensure that the new MVUM is easier and plainer to read than the current maps for the CNF proposal. The maps are difficult to understand. The legend is not consistent and the symbols confusing. For example, the legends suggest that trails open to motorcycles are blue dashed lines with a "l" cross-mark but some of the maps show trails as blue with circles. Similar other problems exist. It is difficult to comment on a proposed action when it is unclear what that action actually entails.

The maps also show winter range as proposed to be open to snowmobiles. Is that accurate? There is an inconsistency as to what trails may be open to snowmobiles. The summer maps reflect certain trails not open to motorized use yet the winter maps show those areas open to snowmobiles. Are snowmobiles proposed to be allowed on these trails? The written documents and maps seem to be in conflict regarding area closures for snowmobiles. For example, there are trails proposed to be closed to snowmobiles on the maps. In some instances these are loop trail systems that effectively isolate areas that appear as open. One couldn't access these areas except by going on the closed trail (or through a closed area like wilderness). Please clarify the maps and clearly answer these questions in the next phase of the process.

ORVs Receive Preference

The Forest Service has dedicated several areas to ORVs without a concomitant commitment to quiet recreation or to resource concerns. Clarke Mountain, Deception Saddle, Laird Park, Boulder Creek, and Sheep Mountain have all been recently set aside for ORV use. Until this planning effort, there has been no attempt to implement the forest plan regarding semi-primitive, non-motorized recreation or meeting the executive orders. As noted elsewhere, the current situation is far from what the forest plan and other laws and regulations mandate. The proposed action is only slightly better than the current situation.

NEPA Alternatives

The DEIS must consider an adequate range of alternatives. Some possible themes to consider would be to restrict vehicles to the 4,000 plus miles of road that exist on the Clearwater National Forest to protect wildlife and watersheds. Another would be to allocate roadless areas for foot and horse travel to protect wildlands, wildlife habitat and watersheds.

Area Protection

Travel planning must include large strategic vehicle closures for ease of enforcement. A trail by trail approach just doesn’t work. On the proposed action map, trails that are closed to vehicles or only open to certain vehicles intersect those that are open. This will create management difficulties and can cause significant confusion among trail users. There is no incentive for someone riding a vehicle to stay on the open trail. In addition, there is a lack of enforcement in remote areas. The forest plan wisely recognized this problem in designated Wilderness and recommended that all trails leading up to the Selway-Bitterroot Wilderness (forest plan page F-2) be closed. Furthermore, a trail by trail approach does not adequately address snowmobiles. We recommend only designating trails in those areas where enforcement patrols will be possible and within the budget constraints of the CNF.

The proposed action has a mishmash of open with a very few closed trails. Weitas Creek is a prime example. For example, trail 625, which is open to ATVs, dead ends at trail 167, which is closed to ATVs. Trail 20 is segmented, from north to south as open to ATVs and motorcycles, closed to ATVs but not motorcycles, closed to all vehicles, open to motorcycles and then open to ATVs and motorcycles. The entire trail should be closed to vehicles, as should all trails that intersect trail 20. The snowmobile portion of the proposed action is unclear. The proposed action is not enforceable or manageable and this should be remedied before the DEIS review is conducted.

The agency constantly complains about declining budgets. It only makes sense to zone out motorized use in remote backcountry areas where non-motorized trails intersect with motorized ones, thus limiting the need for costly patrols of these areas. It also makes it possible for those seeking quiet recreation to truly escape the whine of motors.

In other words, the Forest Service should use a landscape-level approach to travel management, by providing sound sheds with opportunities for quiet use and key wildlife habitat.

The Few Bad Apples Myth

In a recent study from Utah State University, researchers found that nearly half of riders prefer to ride "off established trails." Of the OHV riders surveyed, 49.4% prefer to ride off established trails, while 39% did so on their most recent excursion. Of the dirt bike riders surveyed, 38.1% prefer to ride off established trails, while 50% did so on their most recent excursion. These preferences should not be legitimized by designation of illegal routes (Institute for Outdoor Rec & Tourism, USU, 2001).

Another survey from Monaghan and Associates in Colorado reaches similar results. An example from the Fishlake National Forest illustrates the issue in another way. The agency found 1200 miles of illegally created routes on the Fishlake National Forest. It is more than a few bad apples that are creating thousands of miles of illegal routes. These surveys dispel the few bad apple myth.

Last year's motorcycle jamboree, held on the adjacent Nez Perce National Forest, also shows there are more than just a few bad apples. This group, which supposedly had some State of Idaho sponsorship, violated the terms of their MOU with the Forest Service. Friends of the Clearwater also monitored this event and discovered illegal use on the only two closed trails in the area. The Forest Supervisor of the Nez Perce National Forest told us that she shut down the event. Rather than a few bad apples, it is a culture of abuse when dealing with ORVs on public land.

Friends of the Clearwater monitoring has also found illegal use in the very few closed areas on the Clearwater National Forest. In the winter, we have routinely documented illegal snowmobile use in and around Tom Beal and Elk Summit. We have documented illegal use in upper Fish Creek causing damage to the meadows.

Limiting the areas and trails that are open to ORVs will help to control the damage that occurs from this illegal behavior and will increase effectiveness of enforcement patrols, as mentioned previously.

Impacts

There is a plethora of research showing the negative ecological impacts of ORV use. We refer you to the Wildlands CPR website, which has a bibliographic database on the impacts of off-road vehicle use, including snowmobile use. See www.wildlandscpr.org. These impacts take many forms, including habitat fragmentation, increased human access and encounters with wildlife (crucial for large carnivores and some big game), impacts on aquatic species (erosion and direct impacts from use of ORVs in streams), soil compaction, noise (wildlife and humans), pollution, and impacts to quiet recreationists. The Forest Service should also comply with the executive order on noxious weeds (EO 13112), by limiting roads and trails that serve as vectors for the spread of these species. Simply put, ORVs create many negative impacts. The DEIS needs to analyze the impacts of ORVs from many perspectives.

The recent discovery of a grizzly in the North Fork illustrates the need for action. Grizzlies need secure habitat. There is wonderful grizzly habitat in the roadless areas of the Clearwater National Forest. Weitas Creek (Bighorn-Weitas), Kelly Creek (Hoodoo, also called Great Burn), Vanderbilt Hill (upper North Fork/Meadow Creek) and Pot Mountain Proposed Wildernesses are all areas that have had reliable sightings after the last confirmed (dead) grizzly was found on the Clearwater National Forest (see Grove and Melquist's reports from the 1980s, published by Idaho Department of Fish and Game).

Winter snowmobile use has been implicated in some studies as drastically affecting wolverine, fisher and lynx habitat. While the CNF is outside of mapped core habitat for lynx, it is considered "occupied" habitat by the agency. The DEIS must ensure that it complies with protective measures for lynx including the management direction for winter recreation planning.

There is good evidence that snowmobiles displace wolverines and may reduce reproductive success, especially in denning habitat. Jeff Copeland noted that snowmobiles and denning habitat for wolverines might not be compatible. His research has shown that wolverines and their young are vulnerable to human disturbance in mid-February through early May. This is the same time when snowmobiles use occurs in high elevation denning habitat. Indeed, Copeland notes, "Technological advances in over-snow vehicles and increased interest in winter recreation has likely displaced wolverines from potential denning habitat and will continue to threaten what may be a limited resource."

It appears the Bitterroot Mountains are the dispersal corridor for wolverines in the entire US Northern Rockies. Impacts on wolverines must be considered in that light.

Recent research suggests the fishers in the Clearwater are native and not descended from reintroduced animals. As such, they are an important ecological component of the forest. Snowmobile access in fisher habitat could make them more vulnerable to traps set for other species.

Monitoring levels of snowmobile use is crucial. The Clearwater National Forest has failed to monitor activities from motorized use, contrary to direction in the forest plan. This monitoring information is important to analyze impacts of motorized recreation on lynx, wolverine and fisher.

Roads System

The Clearwater National Forest has between 4,000 and 5,000 miles of roads. It is instructive to note that, apparently, the latest numbers for road mileage are under reported. When one subtracts the amount of road obliteration from the mileage reported in the annual forest plan monitoring reports and compares that with the number of miles of roads, there is a glaring inconsistency. In other words, over the past several years, the road system mileage has decreased to a much greater extent than the road obliteration mileage would indicate. Given the number of miles of roads open to ORVs (and not full-sized vehicles) and the fact that most roads that are open to full-sized vehicles on the Clearwater National Forest, are also open to ORVs, it makes sense to close trails to motor vehicles to provide opportunities for quiet recreation and to protect wildlife, watersheds, cultural values, and rare habitats.

Roads to Nowhere

The Notice of Intent is not clear whether this is comprehensive road, trail and vehicle planning. This is important as there are roads and trails, which are not, indicated in the maps packets. It is assumed they will remain open regardless of the resource damage or economic problems. Many roads to nowhere should be considered for closure and obliteration as part of a comprehensive travel planning process, and as directed in the Travel Analysis process outlined in the draft directives implementing the travel management rule. Some already are proposed to be closed or are closed like the Gospel Hill and Rawhide Roads. Others that should be considered are:

Coolwater Ridge (317, 331)
Elk Summit (360, 358, 359)
Savage Ridge 111
Tom Beal 362
Boundary Peak (485)
Horseshoe Lake (588)
Castle Butte 561
Liz Butte (560)
Weitas Butte (557)
Weitas 555 beyond the bridge
Toboggan Ridge (581) this road is open for such a short time, maintenance is costly
Black Canyon Section (250) this road is expensive as rockslides routinely block it
Fly Hill/Gospel (720, 715)
Fish Lake/Goose Creek (295)

Other roads or road complexes that could be considered for restoration or closure include

Fish Butte (483, 481, 5545)
Gravy Creek (587, 107)
Weitas (555 and 103) before bridge, this steep road is unstable in places
Mush Saddle (711)
Smith Ridge (700)
Hidden Fix
Skull Creek
Deception/Osier Ridge

Trail Conditions

Many of the trails listed as open or proposed to be open in this travel planning process are not maintained for wheeled vehicle travel. We have documented places where wheeled vehicles have deviated from the trail and caused resource damage. Motorized vehicles deviated from the trail because it was not designed for vehicle use and presented natural barriers or, in some instances, the trail was closed to vehicles and the vehicle users apparently decided to parallel the trail in an effort to avoid detection. In an era of declining dollars for forest management, it makes no sense to encourage motorized use on trails where such use will lead to resource damage or possible accidents due to the rugged nature of the trails themselves.

Trail System not Designed for Vehicle Use

Forest Service trails were not originally designed for any vehicle use. They were designed for stock or foot travel, mainly for agency personnel. Other trails followed existing trail treads that were historic in nature (mainly Nez Perce routes) or game trails. Vehicle use on these routes can have negative effects on heritage vales as well. Full surveys of cultural or archaeological resources should be completed in conjunction with the NEPA analysis of effects and in compliance with the National Historic Preservation Act.

Any vehicle use creates a constant erosion path, unlike foot travel. Trails used by two-wheeled vehicles create a u shape with an erosion path. Maintenance of such trails is more expensive as water bars need to be more massive to combat the erosion created by vehicles.

Sensitive Areas

All roadless areas and contiguous land should be closed to motor vehicles. These are the remaining wildlands in the US and they need to be free of vehicles. The vast majority of land is dedicated to vehicle use. Enclosed is a map of HR 1975 (the Northern Rockies Ecosystem Protection Act) for the Clearwater National Forest. Specifically, the areas in HR 1975, which would be designated as wilderness, must be closed to vehicles.

All Research Natural Areas need to be closed to vehicles, as do riparian areas (RHCAs). The travel plan should contribute to attainment of the riparian management objectives in the Inland Native Fish Strategy (INFISH) and the Pacific Anadromous Fish Strategy (PACFISH) and should comply with the standards and guidelines in these Forest Plan amendments.

Motorized roads and trails should not impact core or critical habitat for sensitive, threatened and endangered fish, wildlife and plants. Open route densities should not exceed habitat effectiveness for these species, nor should they exceed the standards for elk habitat effectiveness. That means that no motorized use can be allowed in areas where elk habitat is to be maintained at the 100% level.

One of the biggest problems is that areas (currently and in proposed action) and some routes lead up to or go into designated Wilderness. This is poor policy and invites illegal use. Even inadvertent illegal use in the wilderness could result. A person on a snowmobile may miss the boundary sign and keep going. Indeed, there is considerable illegal snowmobile use in and around Tom Beal and Kooskooskia Meadows/Elk Summit.

The travel plan should be consistent with the Wild and Scenic Rivers Act and the comprehensive management plan for each WSR segment (e.g. dispersed campsites along WSRs should not degrade WSR characteristics). In essence, ORV use in wild and scenic river corridors is inconsistent with the law.

Seasonal designations of motorized routes should exclude spring wet periods when the potential for erosion, sediment delivery and mass failures are high. The agency should identify and reclaim motorized roads and trails located on sensitive land types.

Motorized roads and trails should avoid further impacts to water quality. Some areas are heavily damaged, including but not limited to Lolo Creek, Quartz Creek, the Palouse River, and Orogrande Creek.

Trails that go through areas of historic and cultural significance should not be open to vehicles to protect heritage values. Full cultural resource surveys should be conducted for all areas open to motorized vehicles, including the 300 foot buffer for dispersed camping. These access areas are all considered part of the Area of Potential Effects (APE).

Friends of the Clearwater and others have conducted extensive monitoring of ORV use (including snowmobiles). Your office has received monitoring reports (including photos) and letters documenting problems such as resource damage and illegal use. These provide strong evidence that all roadless and sensitive areas need to be closed to vehicle use. Such an alternative would still leave thousands of miles of routes open for use.

One observation from continued monitoring serves as an instructive example. We have seen over the years the effect of snowmobiles on wildlife. Overflights--not too many years in the past though prior to the time when most snowmobiles were the new and lighter machines--showed little use in backcountry or roadless areas. The nature of the Clearwater National Forest is such that ungulates, especially moose and elk, can use areas with deeper snow in the winter. We commonly observed ungulate tracks and trails in the snow a few years ago as well as forest carnivore tracks

It now seems that ungulates are being concentrated in areas where snowmobilers don't desire to go and wolverine tracks are much less frequent. Natural dispersion patterns have been upset and this may lead to reduced vigor and increased stress of ungulates. In particular, such impacts have been observed in the backcountry in and adjacent to the Kelly Creek (Hoodoo/Great Burn) IRA and areas in the upper Lochsa. We discuss other problems we have encountered in the area-specific portion of this comment.


Dispersed Camping Exception

Allowing a 300 foot buffer for dispersed camping purposes is contrary to the intent of the Travel Management Rule and will make determining the cumulative impacts of the proposed action nearly impossible. Instead, the CNF should consider designating specific dispersed camping site spurs that can be driven to and only allowing individuals to park within one vehicle length of the road if it is safe to do so. This will make surveys for cultural and other resource impacts and the analysis of the impacts of the proposed action must simpler.

Specific Areas

The specific comments that follow are based almost exclusively on roadless areas (which would be designated as wilderness in HR 1975) and immediately surrounding areas. The areas that don't fit this category are clearly marked as such.

Also, other comments provided by Gene and Mollie Eastman give detailed trail descriptions. They reflect extensive on-the-ground experience and are incorporated here by reference.

Weitas Creek (Bighorn-Weitas)--Proposed Wilderness

Weitas Creek is the most important roadless area on the Clearwater National Forest. Indeed, the Idaho Department of Fish and Game (back when the professionals were not subject to current anti-wildlife and anti-fish politicians) recognized the unique ecology of this area. The IDFG it was the most important area for wildlife on the Clearwater National Forest during RARE II.

Perhaps no place illustrates the degradation of quiet recreation as does Weitas Creek. Over the years, places that were not used by motor vehicles (or used only lightly), have been opened to that use without any NEPA. We refer you to the Friends of the Clearwater 2001 Monitoring Report and other letters and reports that provide detailed information.

This area has considerable abuse by vehicles in certain areas. The management of this area for vehicles violates the forest plan, forest plan ROD, executive orders and the forest plan settlement agreement. We have also encountered illegal pioneered routes in the roadless area that lead from currently unmaintained trails that are apparently no longer part of the trail system.

The Forest Service correctly recognizes that any area that appeared in one of the bills introduced by former representative LaRocco--be it a proposed wilderness or a special management area-- must be managed as per the settlement agreement (B-2) (see Middle-Black Draft EIS, figure 6 between pages 106 and 107 which recognizes all proposed wildernesses and special management areas in that category.) Everything from and including Weitas Creek, Little Weitas Creek and trail 20 to the east falls into that category. The Forest Supervisors letter of March 30,1993 makes the point clear that any B-2 (or settlement agreement B-2 area, for that matter) cannot have trail reconstruction and have that area open to motorized vehicles. 531and 167 fall into that category as do others. The Clearwater's ORV guidelines of July 19, 1995 also reiterate that point. Page 30 of the guidelines admits that motorcycle use in Weitas Creek has increased due to recent reconstruction of trails.

Pages 13 and 17 of the ORV guidelines clearly note that ATVs are not permitted on trails in C-1 and C-6 management areas, the reason being protection of wildlife habitat. Furthermore, even if one ignores the settlement agreement (which cannot be done), much of Weitas Creek is in management areas C-1 and C-6, trails must be closed to all motor vehicles if they have been reconstructed (see ORV guidelines pages and ATV use of any kind is prohibited even in the absence of reconstruction 1(3 and 17). Also, the forest plan ROD allocates C8S areas to nonmotorized use.

Lack of regulatory signs at the trailhead is a major problem for the entire Weitas Creek Proposed Wilderness. Also, many trails, according to the Trail Guide, are not suited for vehicle use but are proposed to be open.

Trails that are proposed closed to vehicles or only open to certain vehicles intersect those, which are proposed open. This creates management difficulties and can cause significant confusion among trail users. There is no incentive for someone riding a vehicle to stay on the trail open trail when it intersects a closed trail in a remote area.

The outstanding natural values, the current trail conditions, and user conflicts all dictate that all the trails in the Weitas Creek Roadless Area should be closed to all vehicles. In any case, many of those trails currently open must be closed in order to comply with forest plan standards, the settlement agreement, and the ORV guidelines.

Much of Weitas Creek is lower elevation and/or winter ungulate range. The higher elevations provide lynx and wolverine habitat. Snowmobiles are inappropriate in this area.

Routes:

555(r) This unmaintained old road should be closed to all vehicles beyond the bridge. Even he Forest Service recognized that if Weitas Creek were to be designated wilderness, this route should be closed and become part of the wilderness (see forest plan EIS appendix C).

17 close this trail to vehicles. The trail near Hemlock Creek is not easily locatable anyway. Trail #517 Bighorn Pt. should be closed to vehicles.

104 close this trail to vehicles. The trail near Hemlock Creek is not easily locatable anyway

670 and 674 are within the Hemlock Creek watershed. This is a unique stream that Dr. Fred Rabe has nominated for RNA status. They are not frequently maintained.

20 we have documented considerable damage along this trail. All of this trail should be closed. Under the proposed action, some of it would be closed but most would be open to motorcycles and/or ATVs. Such a mish mash is not manageable or enforceable in the backcountry.

167 Even though this is a ridge trail, there is damage from vehicle use along it. It should be closed. It was reconstructed yet not closed to motor vehicles even though that violates the forest plan, forest plan settlement agreement, and the ORV guidelines. Like trail 20, this is a mishmash of open and closed that can't be properly managed.

667 and 627 would be open where they cross the proposed closed portion of trail 20. Both should be closed to vehicles. Trail 627 is very deteriorated in places and both are very steep in places and not suited to vehicles.

626 is open to ATVs but crosses 167 which is not. It should be closed to all vehicles.

112 and 123 would be open. Both are infrequently maintained single paths. One leads to an old, high-elevation cedar grove. Both should be closed.

599 to Bald Mountain Lake is an example of illegal use dictating policy. It should remain closed to all motorized use.

649 and 650 Trail 650 intersects two closed trails. It should be closed. (Note, Liz Butte detailed map is missing from scoping documents). Also, 649 has a closed section in the middle of it. The entire trail should be closed to vehicles as this makes no management sense.

117, 594, 532 and 593 see little use and are narrow. They are unsuited for vehicles and deep within the backcountry. 593 is steep and abandoned.

524 is a trail the Forest Service illegally promotes for ATV use. It is in a management prescription that prohibits ATVs to meet summer elk habitat. It should be closed to all vehicles.

532 goes along Cayuse Creek, a world-class fishery. It should be closed to vehicles.

Pot Mountain Proposed Wilderness

This may be the wildest area on the Clearwater national forest. As our monitoring has shown, signage at trailheads is usually missing. These trails are not designed for motor vehicles and erosion is present where evidence of motorized use was seen.

The trail guide lists the trails in this area as good for hikers and stock. That guide reaffirms our recommendation that the trails in Pot Mountain be closed to vehicles.

The higher reaches of Pot Mountain are prime habitat for mountain goats and for wolverine denning. Keeping this area closed to snowmobiles as essential for wildlife protection.

Routes:

144 is closed then open. It accesses the Chateau Rock. It should be closed entirely.

154, 160, 617 and 124 are all steep, narrow and in some cases rarely maintained. They are not suited to motorized use. Trail 617 goes to the Chateau Falls RNA.

Selway-Bitterroot Proposed Wilderness Additions
(North Fork Spruce, Sneakfoot, Lochsa Face and Gedney)

these are some of the most important wildlife habitat and watersheds in the Clearwater drainage. All of this area used to be part of the old Selway primitive Area and had more protection 1963 than it does today. The entire area is important forest carnivore habitat (wolverine, fisher and lynx) and may contain grizzlies. It includes anadromous and resident fish habitat.

Motorized use is incompatible with proper stewardship of the adjacent Selway-Bitterroot Wilderness. While most trails (except two problems noted below) are closed during the summer, the winter use creates severe problems. indeed, the maps shows that one route allows illegal use INSIDE the Selway-Bitterroot Wilderness. The Powell Winter Map would allow use on the old Kooskooskia Meadows route which goes into the Selway bitterroot Wilderness about one quarter mile. Also, snowmobile use would be allowed in the Sneakfoot RNA and that is incompatible with protection of that area. Much illegal snowmobile use in the wilderness occurs because the Forest Service has failed to engage in appropriate action to close the Elk Summit road at the first bridge, which would be very easy to do, to snowmobile use. We have documented illegal use on overflights. The forest plan standards would be violated by this proposal. All of the roadless areas need to be closed to snowmobiles and the Elk Summit road should be closed at the first bridge over Crooked Fork during the winter just as the bridge to Wilderness Gateway is proposed to be closed.

Routes:

909 goes into the old Selway Primitive Area near Savage Pass. It is not suited to motor vehicle use. this area is a nonmotorized setting.

940, which is near the roadless boundary, goes into wild habitat around Rudd Moore Lakes. This is a sensitive area not suited to motor vehicles. An damaging fire line was constructed along this trail during the beaver lakes fire of 2003.

The Tom Beal, Elk Summit and Savage Ridge Roads should be considered for possible restoration. The Savage Ridge Road literally goes nowhere. Elk summit and its spurs, especially the Kooskoosia Meadows spur are low standard dead ends. At the very least, they should be closed in winter as they invite illegal snowmobile use into the Selway-Bitterroot Wilderness which has been an increasing problem.

Mallard Larkins Proposed Wilderness

This area is important mountain goat habitat and a popular backcountry area. Much of the area is proposed to be closed to vehicles which is positive. However, the Elizabeth Lakes area should be closed summer and winter to vehicles to protect wolverine denning and provide consistent management.

Routes:

101 should be closed to vehicles. It is an old trail predating Euro-American influence according to Ralph Space and has considerable cultural value.

169, 76 and 445 lead to Cold Springs Peak. This area currently sees illegal off trail use. All trails should be closed for consistent management


Kelly Creek/Great Burn (Hoodoo) Proposed Wilderness

This wild area is a prime wilderness candidate. It has crucial wildlife habitat for carnivores including grizzlies. There is one terrible problem with the proposal, keeping the 419 trail open to motor vehicles including ATVs. Your office has detailed information about the damage vehicles have created in this unique area (a high elevation lake that naturally ahs fish).

The winter use map is confusing. Will the 419 be open or closed to snowmobiles? Why are the Little Moose Creek and Swamp Creek drainages open to snowmobiles?

Fish Creek/North Lochsa Slope Proposed Wilderness

This area is the most important wild steelhead stream in Idaho. It provides important year-round wildlife habitat and should be closed to vehicles in the winter, yet it is proposed to be wide open (with the possible exception of mapped winter range and a few trails). Here, the FS logged open on old trail (229) and dedicated it to ATV use even though such an action is prohibited in the forest plan. Other trails that are open violate the forest plan. Allowing winter use everywhere does not protect winter habitat and violates the forest plan. Also, many narrow trails closed to summer vehicle use are open to snowmobiles. This will cause resource damage and unnecessary trail widening.

Routes:

229 trail should be closed to all vehicles. It goes down to Fish Creek and has been damaged by extensive trail widening. Leaving this trail open violates the forest plan. The

2 parallels the Lochsa. It is traditionally used by nonmotorized hikers on an easy route and should be closed to vehicles.

2230 is a very steep trail that is sloughing off the mountain near its northern terminus. It should be closed to all vehicles.

2240 is the route up Fish Creek. It is steep and narrow in places. Vehicle use is inappropriate as it is a popular hiking trail.

241 goes from 2240. It is a very narrow tread inappropriate for motorized use as it will cause increased erosion.

225 is very steep and barely maintained. It also goes through a wet meadow and is not easily locatable an not suited for vehicles.

203 is hard to locate. Proposing it for an ATV trail (it is not currently open for that use) violates the forest plan. Any vehicle use is inappropriate. there are steep and rocky sections with jump-offs. Wet meadows near the top are vulnerable to vehicles.

201 is a narrow trail not suited to vehicles. Resource damage will occur.

231 from Castle Butte is not suited for vehicles and not maintained very often.

204 is a steep trail that accesses a rare high-elevation cedar grove. It should not be open to any vehicles as resource damage would be too great. It is not frequently maintained.

The remaining trails are all within watersheds that have been damaged n the past as these watersheds are only partly unroaded. Vehicle use on these steep trails should not occur

192 and 705 are infrequently maintained and narrow paths. they are not suited for vehicles.

116A is near the boundary of the roadless area. It is infrequently maintained though proposed open to ATVs. Vehicle use is not appropriate in this area.

142 is not well maintained and should be closed to vehicles

116 is the Van Camp route that goes through the Lochsa RNA. it should be closed to all motorized use.

142 near glad creek is not well maintained and unsuitable for vehicles.

111, 107 and 110 have had recent trail work but 107 has an old bridge out over Canyon Creek. they should be closed.

708 near the roadless areas boundary is the old historic trail and should be closed to vehicles to protect the cultural values.

The following roads should be considered for restoration as they are in sensitive areas and are roads to nowhere:

Boundary Peak

McClendon/Middle/Fish Butte

Upper North Fork Proposed Wilderness

The proposed summer management for this area is positive. However, it is important winter habitat and should be closed to snowmobiles. It is the corridor between the St. Joe and North Fork Clearwater drainages.

Moose Mountain Proposed Wilderness

This steep rugged area has few trails. It is allocated to non-motorized management. However, winter snowmobile use seems to be allowed in a portion of Ruby Creek, which does not make much on-the-ground management sense.

Weir Creek Proposed Wilderness

This small gem is a very wild with only one maintained trail in it. Unfortunately, the FS proposes to open the trail to motorized use. 919 is narrow and steep and not suited to vehicle use. Winter motorized use is allowed everywhere except for, ironically, on the 919 trail and possibly in winter range.

Siwash Proposed Wilderness

This area contains some important coastal disjunct habitat and winter range. However, it is wide open to snowmobiles and all trials are motorized. The 601 and 602 trails meet yet have different proposed restrictions.


Eldorado Creek Proposed Wilderness

this small area is all that is left of the gentler terrain on the western portion of the main black of the Clearwater National Forest. Most of this area has been heavily developed. As such, it has ecological importance. Closing the area year-round to vehicles is imperative.

48, 31, 32 and 58 are narrow trails and in the case of 31 and 48 hard to locate. 48 is a historical route. They are not suited to vehicle use. part of the boundary fire of 2007 burned in this area.

Other Sensitive Routes/Areas

Historic trail conflicts occur along the 34, 11 and 541 trails which would be open to motorized use. In addition, the 5950 road should be closed as it is right on an old trail of significant cultural value.

The 88 trail is narrow and should not be open to ATVs. The 297 trail is the only unroaded place on the North Fork Clearwater where the river has some size. As such, it should be closed to motorized use. it is also near the Aquarius RNA.

Palouse District

This area is heavily developed and logged. There is little opportunity for backcountry recreation. Two tiny places--Elk Creek Falls and Boulder Creek (Potlatch River) have very short trail segments closed both summer and winter. Otherwise, everything is dedicated to motorized use, at least most of the year.

The area around White Pine is proposed to have trails closed to snowmobiles. While that is positive, there is not an are closure so it begs the question whether the agency intends to close the area or just the trails in the area. If the latter, what about snowmobiles crossing trails to go into the wide open "in-between" areas?

Consideration should be given to nonmotorized recreation in and around White Pine for summer use. Closing trails 223 and 221 to motorized use could be considered or closing some of the trails around the Giant White Pine Campground (east of the highway).

Summary

All roadless areas, RNAs, and other sensitive areas need to be closed to vehicles, summer and winter. In some instances, the roads may also need to be reclaimed. In the interim, all trails not designed for motor vehicle use (that is all of them except for rare exceptions) need to remain closed to meet the direction of the executive orders. In the interim, snowmobiles should be restricted to designated routes to protect wolverine, fisher and lynx habitat as well as ungulate winter range. Historic trails should not be open to vehicles to prevent loss of cultural resources.

Sincerely,



Gary Macfarlane
Friends of the Clearwater
PO Box 9241
Moscow, ID 83843
and for Alliance for the Wild Rockies

Sarah Peters
Legal and Agency Liaison
Wildlands CPR
PO Box 7516
Missoula, MT 59807

Andrew Orahoske
Conservation Advocate
Center for Biological Diversity
PO Box 9174
Missoula, MT 59807

Cameron Naficy
WildWest Institute
PO Box 7998
Missoula, MT 59807

Mike Petersen
the Lands Council
25 West Main, Suite 222
Spokane, WA 99201

Montana Backcountry Alliance
Adam Switalski
PO Box 8691
Missoula, MT 59807

Gene and Mollie Eastman
Friends of the Lolo Trail
4160 Four Mile Road
Weippe, ID 83553